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Home My WebLink About06-0950 mil BRIAN M. PRATO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. OL- 9996 Clot- JZ VALARIE C. PRATO, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A -judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3302 Telephone: (717) 249-3166 1 VdivA2RA-c,ipIA6=v0-C BRIAN M. PRATO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01?- QSd ?ULC? L?IL l VALARIE C. PRATO, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT 1. The Plaintiff in this action is BRIAN M. PRATO, an adult individual, who currently resides at 528 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant in this action is VALARIE C. PRATO, an adult individual, who currently resides at 528 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on November 22, 2002, in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is -1- i irretrievably broken. 7. The Plaintiff avers that no children have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 P.C.S. §4904, relating to unsworn falsification to authorities. Date: O //Z/ ld6 Zlel-- B N M. PRATO, Plaintiff STONE LaFAVER,-& S TSKI By Eli abe B. ne p C rt D #'60251 B ge S eel, P.O. Box E New umberl d" PA 17070 Telephone IV-77 4-7435 Attorn s or Plaintiff -2- O W ?n 01 .: '. ai. v A PHATO, GRiAN-a _'io fse rvi ce rA: BRIAN M. PRATO, Plaintiff V. VALARIE C. PRATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-950 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, Valarie C. Prato, at 528 Hogestown Road, Mechanicsburg, Pennsylvania 17055, by United States Certified Mail, postage prepaid, return receipt requested, restricted delivery, on March 6, 2006' as evidenced by the attached Certified Mail return receipt. ri?> i,ok-abeth X. St torney t Law SWORN TO AND SU SED b th's day 20X y Public '? COMMONWEA..TSi OF PENNSYLVANIA NQI"ARIAL SEAL DANIEL M. HART MAN, Notary Public New Cumberland Boro., Cumberland Co. My Commission Expires Jan. 21, 2009 ra ti NECHANICS&URG PA 17055 a P..t.g. s 39 C3 Certified Fee _ ({ t ? O i , ??UGPOS? M1 Return Receipt Fee Mere (Endorsement Required) O Restrictetl Delivery Fee f- (EndorsementFecund) O Total Postage & Fee. $ r? 11t16 Rl N Name (Pleese P n clearly) (7be (o?np/ fed by matter) M ----- '!1 --: r( - --------------------------- Q. Stre t, A t N . or PO B z No. 5?e , ? n - ..-. 3 city, r .. zi , a l , _ & 1 1175 r ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, nr on fhn frnnf if cnnop ncrmits 1. Article Addressed to: 5?`byesl mu in (Y)eCIAO VliC&Uu'C' , YES, enter delivery address below: O ress Mail Return Receipt for Merchandise 2. Article Number (COPY from service label) 1099 3"3ao ucxO-7 0201 _70 9 PS Form 3811, duly 1999 Domestic Return Receipt '02595-00 M-0952 n-1 ,? ?'. t'?i ,r. rr G'. f1Vd1V%,F PP,Tp, BRAN-af f ofcocse n`_ BRIAN M. PRATO, Plaintiff V. VALARIE C. PRATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-950 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 17, 2006, and served on March 6, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifica- tion to authorities. ,-62 7, Dn(. Date i f? f B M. PRRATO, Piain ff G: ?., ,-, ;, -,, r ?? -u , ?_ , ;?.. ?? _;, ?;> r,: fl\drr ,2BATO,BHIAN-arforconsent BRIAN M. PRATO, Plaintiff V. VALARIE C. PRATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-950 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 17, 2006, and served on March 6, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifica- tion to authorities. Date VAL'ARIE C. PRATO, Defen n "' c: s ?, _ =,, ...? ;}?. C_ =F -? 4. C 7 -.,_? . '. , -;-,` i J '.] fLAdivAPRA'"O, BR'AN-Walverm Enot-ce BRIAN M. PRATO, Plaintiff V. VALARIE C. PRATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-950 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifica- tion to authorities. Jvu,kt -7, D?CP Date BRI PRATO, Plaintiff -2- r? ?.y :? . ti, C' _.__ ,? ? ".? " " r. : t.? _ i ,n od ER9TO, 3R TAN- w...... fnorE,, BRIAN M. PRATO, Plaintiff V. VALARIE C. PRATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-950 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I uer,fy that the sta Fm.,nts ...ado _. th .. affrdac t a-e true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifica- tion to authorities. Date VAL RIE C. PRATO, befen&a?rt L? C1. .Y _ r._ ? ? _ T; f ,y 1J (;,) BRIAN M. PRATO, Plaintiff V. VALARIE C. PRATO, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: March 6, 2006, U.S. Certified Mail postage prepaid return receipt requested, restricted delivery . 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff June 7, 2006 ; by Defendant June 7, 2006 . (b)(1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-950 Civil Term Elizabeth B. Attorney f9z r_ Y - tv CID IN THE COURT OF COMMON PLEAS BRIAN M. PRATO, Plaintiff VERSUS VALARIE C. PRATO OF CUMBERLAND COUNTY STATE OF PENNA. NO. 06-950 Civil Term Defendant DECREE IN DIVORCE AND NOW, nm_L , , IT IS ORDERED AND DECREED THAT BRIAN M. PRATO, AND VALARIE C. PRATO , PLAINTIFF, ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No claims raised BY THE COURT: v ?-- U A ST: - 1z PROTHONOTARY 4kV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VA 0 Plaintiff 4!5p Vs File No. ) .0 ` IN DIVORCE l Ptak Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking `Y ] or rior to the entry of a Final Decree in Divorce, after the entry of a Final Decree in Divorce dated UC ?./r. IJr.r t *1 hereby elects to resume the prior surname of written no 'ace av wing his / her intention pursuant Date: Si of name being resumed COMMONWEALTH OF PENNSYLVANIA ) Wine- l;tlU dal - v tVA *COUNTY OF & 4-be44A* On the ag"k-day of 046ber , 240_7 before me, the Prothonotary or the notary public, personally appeared the above affant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary Public NOTARIAL SEAT. PROTHONOTARY. NOTARY RMIX CARLISLE CUMBERLAND COM COURTHOUSE W COMMISSION EXPIRES JAMUMY 4.2010 N `? c 4 Lo - t- ?i -=t 4i T ? ?,? ??yrtt :? r5 v